QR code menus are now normal in UK cafés, pubs and restaurants. Guests scan a code, browse on their phone and often order and pay without speaking to anyone. So how do you make sure customers with food allergies get the information they need?
The law does not change because your menu is digital, and the Food Standards Agency (FSA) has guidance that speaks directly to digital and online information. This article covers what the rules require, what the FSA recommends, and how to keep a QR menu accurate.
Not legal advice. This article is a general overview for UK food businesses, based on FSA guidance at the time of writing (October 2026). Rules can change and can differ by nation and by the way you sell food. Check the official guidance and speak to your local authority's food safety team or a qualified adviser about your own business.
The legal basics: the 14 allergens
UK food law requires businesses to tell customers if food contains any of 14 major allergens. The FSA's allergen guidance for food businesses lists them as:
- Celery
- Cereals containing gluten (such as wheat, rye, barley and oats)
- Crustaceans
- Eggs
- Fish
- Lupin
- Milk
- Molluscs
- Mustard
- Peanuts
- Sesame
- Soybeans
- Sulphur dioxide and sulphites (above 10 parts per million)
- Tree nuts
This covers these allergens wherever they appear in the final dish, including additives and processing aids.
The rules come from retained EU Regulation 1169/2011 on food information to consumers, enforced in England by the Food Information Regulations 2014, with equivalent regulations in Wales, Scotland and Northern Ireland. The FSA's guidance applies to England, Wales and Northern Ireland. In Scotland, Food Standards Scotland is the relevant body, so check its guidance if you trade there.
FSA business guidance formerly on food.gov.uk now redirects to GOV.UK, so the official links here point there.
Three ways you might be selling food, and the rules for each
The rules depend on how the food is sold. Most venues with QR menus deal with at least two of these.
1. Non-prepacked food (made to order or served loose)
This covers most dishes ordered from a table, counter or QR menu. According to the FSA, you must provide allergen information for every item that contains any of the 14 allergens. Legally, that can be done in writing (on a menu, chalkboard or information pack) or verbally, as long as there is a clearly visible written notice explaining how customers can get the information.
In February 2025 the FSA published best practice guidance on allergen information for non-prepacked foods. It recommends allergen information is easily available in writing, supported by a conversation with staff. The FSA is clear this is a change in best practice, not in the law, but it signals what customers and inspectors will expect.
2. Distance selling (online, phone, app and delivery orders)
If customers order online or by phone, including through your own website or a QR ordering page used for collection or delivery, the FSA says allergen information must be available at two points:
- Before the purchase is completed, in writing (for example on the website or online menu) or orally (by phone).
- At delivery, in writing (such as stickers on containers or an enclosed menu) or orally.
The FSA recommends written information at both points.
3. Prepacked for direct sale (PPDS) and Natasha's Law
Since 1 October 2021, food that is prepacked for direct sale must carry a label showing the name of the food and a full ingredients list, with the 14 allergens emphasised (for example in bold). These rules are known as Natasha's Law, after Natasha Ednan-Laperouse, who died after an allergic reaction to a baguette that did not need allergen labelling at the time.
PPDS food is food packed on the same premises where it is sold, before the customer chooses it. The FSA's PPDS guidance for fast food and takeaway restaurants gives examples such as prepacked sandwiches, salad boxes and breakfast boxes. Food packed at the customer's request, such as a burger served on an open tray, is not PPDS.
The PPDS labelling rules do not apply to distance selling: a sandwich ordered online still needs allergen information before purchase and at delivery, but not the full PPDS label. Grab-and-go items sold over the counter need proper labels regardless of your QR menu.
What the FSA says about digital menus specifically
The FSA's 2025 best practice guidance includes three points that apply directly to QR and online menus.
You can choose paper or digital. The guidance says food businesses can decide whether to provide allergen information in paper or digital format.
Digital needs a backup. If you choose digital, the FSA says you should have an alternative way of accessing the information for people who cannot use the digital version, and as a backup if there is a problem with it. In practice, that means a printed allergen matrix or folder behind the counter. A dead phone battery, a poor signal or a guest without a smartphone should not leave someone without allergen information.
Keep it close to the menu. For online information on your own webpage, the FSA suggests putting it on the main menu or, failing that, no more than "one click away" with a clear message and link. On third-party ordering sites, customers should be told clearly where to find allergen information before they order.
The guidance also recommends asking customers whether they have any allergen requirements, and that staff check written records rather than guessing. Because QR guests may never speak to staff before ordering, a clear prompt on the menu matters even more.
How to keep a QR menu allergen-compliant
A digital menu can be updated in seconds, which also makes it easy to change a dish and forget the allergens. These habits help.
Start from your recipes, not your menu. Allergen information should come from written recipes and ingredient specifications, reviewed whenever a recipe changes, as the FSA advises.
Tag allergens against each item and each option. A plain burger and a burger with "add cheese" have different allergens. Check that modifiers, sauces, sides and substitutions are tagged too, not just the base dish.
Show allergens on the item, not buried in a PDF. Guests should see allergens while choosing, without leaving the menu.
Add a clear allergy message. Put a short line at the top of the menu, for example: "Allergies or intolerances? Please speak to a member of staff before ordering." This supports the conversation the FSA recommends.
Be honest about cross-contact. If you cannot guarantee a dish is free of an allergen because of shared equipment or a shared kitchen, say so. The FSA advises telling customers when you cannot provide an allergen-free dish, and being cautious with "gluten-free" claims if you cannot control cross-contamination.
Keep a printed version. Print an up-to-date allergen matrix and keep it where staff can reach it. The FSA publishes free templates alongside its main allergen guidance.
Update both at the same time. When a supplier or recipe changes, update the digital menu and printed matrix together, and tell the team.
Check delivery orders. Include allergen information with delivered food, such as a sticker or printed ticket.
Many QR ordering systems include allergen fields. For example, Café QR's QR table ordering lets venues add allergen information to menu items, and its features list includes tagging items against the 14 UK allergens, choosing whether guests see them, and a printable 14-allergen matrix for inspections. Café QR has also published a guide to preparing allergen information for a digital menu. Whatever system you use, it only displays what you enter: accuracy remains the business's responsibility.
If you already use digital food safety checklists and SFBB diaries, adding a weekly "allergen menu check" task makes reviews routine.
Checklist
- Every dish, side, sauce and option is checked against the 14 allergens using written recipes.
- Allergens are visible on the QR menu next to each item.
- The menu includes a clear message inviting customers to tell staff about allergies.
- A printed allergen matrix is available as a backup and matches the digital menu.
- Staff know where the allergen information is kept and do not guess.
- Cross-contact risks are explained honestly, with no unsupported "free-from" claims.
- Online orders show allergen information before purchase and on delivery.
- Any PPDS items (prepacked on site) carry full labels with allergens emphasised.
- Recipe or supplier changes trigger an update to the digital menu and printed matrix.
- You have checked the guidance that applies in your nation (FSA or Food Standards Scotland).
Conclusion
Moving to a QR menu does not change your allergen responsibilities, but it changes how you meet them. The law still requires information on the 14 allergens, and the FSA's current best practice is written information backed by a conversation, with a non-digital backup.
Done well, a digital menu can make allergen information clearer and easier to keep current than print. Treat it as part of your food safety system, not just a sales tool: start from accurate recipes, update everything together, and make it easy for customers to ask.
This article is general information, not legal advice. For advice on your own business, contact your local authority's food safety team or a qualified adviser.